K2 Integrity’s Mariano Federici authored an article for The RUSI Journal, “Reassessing Structural and Contextual Constraints in FATF Evaluations” (Volume 171, Issue 5), examining how the Financial Action Task Force’s Mutual Evaluations can better account for the domestic structural and contextual conditions that shape the effectiveness of anti-money laundering and counterterrorist financing (AML/CFT) regimes.
In the article, Mariano argues that although FATF evaluations have evolved from a narrow focus on technical compliance toward a more outcomes-based assessment of effectiveness, they often treat factors such as political stability, rule of law, institutional integrity, judicial independence, corruption levels, administrative capacity, financial inclusion, and regulatory and criminal justice maturity as background context rather than causal variables.
Drawing on fourth-round Mutual Evaluation Reports for Argentina, Brazil, and Mexico, Mariano highlights how governance constraints, politicized institutions, inconsistent judicial performance, corruption exposure, and organized crime can set practical limits on what AML/CFT systems are able to deliver. When evaluations underweight these constraints, the article notes, they risk misattributing structurally conditioned outcomes to implementation failures alone.
Mariano emphasizes that the article is not a call to dilute FATF standards or return to a compliance-centric model. Rather, it makes the case for greater diagnostic precision: effectiveness assessments should more clearly identify which shortcomings can be addressed through AML/CFT reforms and which are rooted in broader structural constraints.
Read the full article in the RUSI Journal. A subscription may be required.